Effective date: July 1, 2020
Local Workforce Development Boards (WDBs), grantees, and/or subrecipients are organizations that are not a part of state government and therefore are not accountable to the state policies that govern records maintenance and retention for state agencies and employees.1 DWD's Division of Employment and Training (DWD-DET) requires that its grantees and subrecipients have local written policies in place to govern access to and retention of grant-related records compliant with WIOA, OMB's Uniform Administrative Guidance, and this WIOA Titles I-A and I-B Policy & Procedure Manual. DWD-DET recommends that its grantees and subrecipients seek assistance from their own legal counsel or records management staff for the development of these policies.2
- 1 The Department of Workforce Development (DWD) is legally responsible for grant records created by DWD employees. These records follow requirements and retention under ADM00013 – Grant Documentation.
- 2 Email from DWD Records Management to DWD-DET, 12/4/2019.
1.6.2 Maintenance and Custody of Records
Effective date: July 1, 2020
DWD-DET requires its grantees to maintain records related to the management and administration of the grant sufficient to:
- supply information for required reporting;
- ensure adequate tracking of funding; and
- ensure lawful expenditures of funding,1 including records related to income or profits earned2 and/or costs incurred that are otherwise allowable except for funding limitations (i.e., stand-in costs).3
All records within the local WDA must be standardized to ensure consistent data collection and reporting.4
All records pertaining to DWD-DET grants are subject to Wisconsin Open Records Statute.5
Individuals' records must be retained in a manner that protects the confidentiality of their Personally Identifiable Information (PII)6 and equal opportunity data and other information.7
Each local WDB must make available to DWD-DET any reports, records, plans, or any other data that is required to be submitted by law, regulation, or policy, or upon official DWD-DET request8 for as long as the records are retained.9
DWD-DET may require the transfer of certain records from the grantee or subrecipient if the organization is no longer able to maintain custody of those records.
DWD-DET requires that records must be retained and stored in a manner that will preserve their integrity and admissibility as evidence in any audit or other proceedings. The burden of production and authentication of the records is the responsibility of the custodian of the records. Electronic retention of records, including the use of cloud-based storage systems, is allowable, assuming the electronic storage meets all other retention requirements outlined in WIOA, OMB's Uniform Administrative Guidance, DWD-DET data sharing agreements, and this policy manual.
1.6.3 Electronic Systems of Record
Effective date: September 4, 2020
DWD-DET has developed and maintains several electronic systems of record for the various types of records required to manage and administer WIOA Title I funded programs:
- ASSET (Automated System Support for Employment and Training) is the system of record for pertinent participant-related information including eligibility, service provision, case notes, and performance reporting.
- CEPT (Comprehensive Employment Planning Toolkit) is the required system of record for economic self-sufficiency determinations and the preferred system of record for individual employment plans (IEP) and individual service strategies (ISS).
(NOTE: CEPT may become the required system of record for IEPs and ISSs in the future.)
- COMET (Contract Management and Expenditure Tracking) is the system of record for all DWD-DET grantee grant/contract fiscal reporting.
- SOLAR (Sharing of Local Area Resources) is the system of record for American Job Center Memoranda of Understanding (MOUs) including Job Center infrastructure costs and other shared delivery system costs.
- JCW Business (Job Center of Wisconsin Business) is the system of record for business services provided through the one-stop delivery system and performance reporting related to business service activities.
- RRETS (Rapid Response Events Tracking System) is the system of record for Rapid Response activities.
DWD-DET requires local WDBs and their subrecipients to use the appropriate systems of record to maintain WIOA grant-related data. Information entered in the electronic systems of record must be supported by all relevant documentation required throughout this policy manual. This documentation may be maintained in paper files or electronic filing systems, including the use of ASSET's document upload functionality. It is not necessary to maintain both paper and electronic records as long as the electronic record contains all required documentation. Local WDBs must have documentation, data entry, and quality assurance policies and/or procedures in place to ensure the integrity of the data provided to DWD-DET. DWD-DET will monitor data integrity and conduct data validation, at minimum, on an annual basis.1
Information entered in DWD-DET's electronic systems of record is considered part of DWD-DET's records and will be retained in accordance with ADM00013 – Grant Documentation.2 This includes participant-specific documents uploaded to ASSET using the document upload functionality.
- 1 WIOA Sec. 185(c)(3); TEGL 7-18, p. 2; Using its discretion, DWD-DET determined that it will monitor data integrity and conduct data validation at least once per year.
- 2 Email from DWD Records Management to DWD-DET, 12/4/2019
1.6.4 Retention of Records
Effective date: September 4, 2020
All records pertinent to grants and agreements funded by DWD-DET must be retained for a minimum of three years.1
This includes, but is not limited to:
|Type of Record
||Three-Year Retention Period Begins
|All financial records, supporting documents, statistical records, and property records.2
||Date of submission of the final expenditure report or quarterly or annual financial report
|All records of real property and/or equipment acquired with DWD-DET administered funds3
||Date of the item's disposition
|All records pertinent to each grant agreement
||Date of submission of the settlement or closeout reports
|All records for program income transactions after the period of performance
||End-date of the entity's fiscal year in which the program income is earned4
|Indirect cost rate proposals and cost allocation plans including indirect cost rate computations or proposals, cost allocation plans, and any similar accounting computations of the rate at which a particular group of costs is chargeable
||Date of submission to DWD-DET for negotiation5 or End-date of the entity's fiscal year (or other accounting period) covered by the proposal, plan, or other computation6
|All records pertinent to each participant's enrollment in programs funded under the agreement, including the dates of entry and termination in each activity
||Participant's common exit date, as determined in ASSET
|All records pertinent to applicants that have been determined eligible, but not served
||Date of the eligibility determination
|All pertinent records of each applicant who is determined ineligible
||Date of the ineligibility/refusal determination; the records must indicate the reason for ineligibility/refusal
|All records pertinent to complaints/grievances, appeals, and resolutions
||Date the complaint/grievance is closed following final settlement of the case.
In any case where a litigation, claim, or audit is started before the expiration of the three-year period, the records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken.7 In these cases, a new three-year retention period will begin on the day the litigation, claim, or audit finding is deemed to be resolved.
In cases where the federal awarding agency (USDOL) requires an extended retention period, DWD-DET may require an extended retention period of its grantees and/or subrecipients.8
The local WDB and/or its subrecipient(s) are responsible for entering required data in the appropriate electronic systems of record, as outlined in Section 1.6.2. Information contained in DWD-DET's electronic systems of record, including participant-specific documents uploaded to ASSET using the document upload functionality, is considered part of DWD-DET's records and will be retained in accordance with ADM00013 – Grant Documentation.
Costs related to records retention are allowable costs and may be charged to the DWD-DET grant.